EPRA - the Good,the Bad, & the big FEE

 EPRA Electronic Products Recycling Association

Today was a day of the upset consumer.

Buy a $150 Television and pay an additional $42.50 for a recycling fee.

There are some pretty upset people out there and they want answers.

Sometimes when trying to listen to politicians on something they have already bungled becomes more and more difficult.

Every now and then for various reasons - I will go at something in an attempt to find the real skinny on the subject. This was one of those times - and is a result of one consumer who got to the checkout and realized they could not afford the purchase. They had received advertising - as is so obvious this time of year - and were delighted to find they could afford a very special gift for their child. The sale meant there would be a very special surprise for one little guy very proud parents that they could achieve this. You probably have guessed by now that they became very embarrassed at the check-out and more importantly somewhat devastated that the surprise for their son had just evaporated.

What happened?

What happened was an environmental recycling fee of $42.50 that they were unaware of and the company had not informed them of in the advertisement.

Time to go backwards:

1. The government decided that electronics must be recycled and that industry players must become stewards of these materials.

2. The regulations were put in place and EPRA was chosen to be the administrator of such a program.

3. This was first advertised by EPRA in July and became effective in August.

4. The MMSB and government worked with EPRA to see the program established.

5. The Government and the MMSB did not conduct public consultation or awareness on electronic recycling and did not involve the public in choosing the agency or corporation private or public that would undertake and manage the program.

6. The public for the most part does not know who the EPRA is and does not know what they do and why they are doing it.

Different electronic products have different fees and they are established by EPRA - all manufacturers and retailers of these products within Newfoundland and Labrador must collect the set fees and remit them to the EPRA. These fees are for the administration, collection, and processing of these materials.

The EPRA is a not-for-profit corporation without share capital and its members are retailers and manufacturers of electronic products.

Currently the EPRA's head office is in Ontario and they operate provincially in British Columbia, Saskatchewan, Manitoba, Quebec, Nova Scotia, PEI, and Newfoundland and Labrador.

First thing that strikes you is that Ontario does not currently operate under EPRA but the national office is there. I write that off to normal arrogance. I am advised however that Ontario will be the next EPRA location.

Now let's get to the fees. The fees are different based on the product but one significant example is for what's termed a big-screen TV. I am told that that is any TV over 30 inches. In Newfoundland and Labrador the fee is $42.50 and is higher than in other provinces - which I am advised is because of additional transportation costs.

In Newfoundland and Labrador there are 17 drop-off locations which is not acceptable if the program is to succeed. Nova Scotia has 39 locations - which when you compare the geography - is ridiculous. There is 55,000 square kilometres in Nova Scotia and 405,000 square kilometres in Newfoundland and Labrador.

Clearly we are going to need some hundreds of locations in this province. With a mere 5,000 square kilometres in PEI - they have 6 drop-off points. So right off the bat we are not rolling this project out in the best possible way.

Once products are dropped off in any of the 17 locations they are forwarded to a collaboration centre in Mount Pearl and from there head to the mainland.

That is to say Newfoundland and Labrador does none of the processing of the products. Our products are shipped to Quebec for processing. Nova Scotia currently has a processor that handles about 20% of their recycling. There is no Atlantic regional facility and that - in my opinion - is a lost opportunity for us.

The choice of processing location I am told was through an RFP (request for proposals) but not within Newfoundland and Labrador. That - in my opinion - was another mistake and we should now work diligently to establish an Atlantic Processing facility here in our province. In that way we can gain employment from this recycling initiative.

The choice for the collaboration facility was not done through tender or an RFP but was done by the company based on their own research - leading to communication with a few potentials and ultimately chosen by them - I am told on the basis of price, service, and experience. This too - in my opinion was a mistake and leaves the door wide open to speculation on why so and so got the contract.

Now for the breakdown. A drop-off location is paid a fee to collect and store materials dropped off to them by us the consumers - then a processing centre is paid to recycle the materials. The processing centres - which are private - for-profit enterprises also retain all revenues generated by selling the recycled materials. Clearly these processors are not paying corporate tax or benefits in our province because we have no processors here. EPRA is paid to administer and manage the program.

I do not yet have specific breakdowns with respect to what percentage of the fee we pay goes to EPRA, the drop off centres, or the processors. I do not know what remuneration is in place for the national and provincial executives. The list of these individuals can be found at the end of this post.
                                                                                                                                                                   EPRA will be tested over the next year and then we can determine if the organization here in our province and in fact nationally is run well. Whether or not the MMSB could have administered this program more efficiently is a question worth asking. Whether or not the best drop-off locations have been established is a good question. Whether or not the best collaboration centre has been achieved is a good question and whether or not we could have done at least a percentage of the processing here is a good question.

There clearly was an opportunity here for government to go after processing these materials for Atlantic Canada and we certainly have enough empty plants etc. to put such a facility in - and our private sector could have been tapped for a partnership initiative.

My experience with EPRA today was mixed. The first phone call I made was to the head office - in Ontario. I was met with significant resistance first and then promised that my questions could be answered by Christy Teasdale, National Director Marketing and Communication for EPRA. I called back at the scheduled time and was left on hold for 45 minutes. I then called the main office again and asked some general questions of the staffer and was further advised to talk to Terry Greene - Program Director for Newfoundland and Labrador. The Executive Director for our region is located in Nova Scotia - in my opinion - another mistake.

Terry Greene is a personable fellow with a good grasp of the company he works for and the program. He was able to answer the questions I had with confidence and for the most part without hesitation. The problems I have with this program are not with him - they are with government and the MMSB.

Before EPRA was chosen for this province there should have been broad public consultations with more than one option for proceeding. Further the government and the MMSB should have taken the transitional lead in the introduction of this program to consumers here in our province.

Secondarily - but as important - are the retailers and manufacturers who are the members of EPRA - they should have collectively decided to conduct responsible advertising and list the environmental fees alongside product costs in their flyers and promotional materials.

EPRA needs to outline its executive remuneration and also more particulars about how are money is spent. Without this information the consumer who pays the fee will be left to speculate on whether or not money is being spent wisely and ethically. It is also important to know that some of our money will be spent in the USA and Europe as some of the processing will be done there.

Is recycling electronic products the right thing to do? Sure it is. Is this the best program to do it? I don't know and I suspect our politicians don't know either. Is EPRA the best company to administer it? I don't know - perhaps the MMSB could have. Are we maximizing our full potential to gain additional employment? No. Has EPRA used the best process in choosing drop-off and processing facilities - I don't believe so. Have the retailers and manufacturers done enough to educate and promote openly this initiative? No. Has the government explained how this whole thing started, why it started, and who started it? No.

Most importantly the fees are determined and established by EPRA without government involvement. Therefore they should have to answer to a PUB like regulator to ensure the fees are appropriate and the expenditures warranted. 

EPRA represents the industry retailers and manufacturers - middlemen to accommodate government regulation. Is this the best process? It's time we had the discussion with the people we elect to govern and make policy and legislation.

The Opposition parties hold some responsibility here as well - where were they when this all went down and what did they recommend?

Chief Executive Officer and Staff

Cliff Hacking

as Chief Executive Officer. 

Other senior EPRA staff includes:

Lynda Kitamura

Chief Financial Officer 

Jay Illingworth

Director of Harmonization

Sean De Vries

Director, Recycler Qualification Office

Christy Teasdale

Director, Marketing and Communications

Each provincial EPRA program has an Executive or Program Director responsible for the day to day management of

the programs:

Craig Wisehart

EPRA Western Canada

Dennis Neufeld

EPRA Manitoba

Dominique Levesque

EPRA-Québec

Gerard MacLellan

EPRA Atlantic Canada